RESTRICTED  
  
WT/ACC/COM/34  
 
5 May 2022  
(22-3515) Page: 1/8 
Working Party on the Accession of  
the Union of the Comoros  Original: English/French  
 
ACCESSION OF THE UNION OF THE COMOROS  
QUESTIONS AND REPLIES  
 The following submission, dated 2 May 2022 , is being circulated at the request of the 
Delegation of the Union of the Comoros.  
 
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  WT/ACC/COM/34  
 
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  TABLE OF CONTENTS  
II. ECONOMIC POLICIES  ................................ ................................ ..............................  3 
- Monetary and fiscal policy  ................................ ................................ ...........................  3 
- Foreign exchange and payments  ................................ ................................ ..................  3 
- Investment regime  ................................ ................................ ................................ ..... 3 
- State ownership and privatization ................................ ................................ .................  5 
- Pricing policies  ................................ ................................ ................................ ...........  6 
IV. POLICI ES AFFECTING TRADE IN GOODS  ................................ ................................ . 7 
C. INTERNAL POLICIES AFFECTING FOREIGN TRADE IN GOODS  ................................ . 7 
- Sanitary and phytosanitary standards  ................................ ................................ ...........  7 
VII.  TRANSPARENCY  ................................ ................................ ................................ ...... 7 
VIII.  TRADE AGREEMENTS  ................................ ................................ ...............................  7 
- OTHER  ................................ ................................ ................................ .....................  7 
 
  WT/ACC/COM/34  
 
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  II. ECONOMIC POLICIES  
- Monetary and fiscal policy  
Question 1  
With appropriate tax reforms, the IMF estimates that the tax wedge could increase 
(by 10 to 12 percentage points to 16 % of GDP). The reform process with significant 
potential impact would require st rong support. Could Comoros please give an update 
about work on setting up its tax administration and give some concrete examples?  
Answer : 
Some updated information is provided below:  
- Entry into operation of the development financing strategy, which proposes reforms to 
achieve a 15 % tax ratio (UNDP Report on financing for development);  
- Entry into operation of technical services and installation of tax management software;  
- Training of General Tax and Property Administration (AGID) officials on various subjects 
including methodology relating to taxation, controls and tax dispute management; and  
- Establishment of an information system (source: Institutional Capacity Building Project 
(PRCI)).  
The Interim Development Plan (PDI  2020-24), a rolling programme i n the context of the Emerging 
Comoros Plan (PCE), provides for the introduction of VAT in our country by 2024. The Financial 
Governance Support Project (PAGF) has planned to carry out a study prior to the introduction of 
VAT. 
- Foreign exchange and payment s 
Question 2  
Could Comoros please confirm that it is still not having plans to change its pegged 
exchange rate regime?  
Answer : 
Comoros does not plan to change the pegged exchange rate regime.  
- Investment regime  
Question 3  
In the World Bank's 2020 "Doing Business" report, in general Comoros was ranked 
160 out of 190 countries. Could Comoros give some concrete examples on what has 
already been done to improve the business environment?  
Answer : 
In order to improve the business environment, clear progress has been made on four 
"Doing  business" indicators, including:  WT/ACC/COM/34  
 
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Other actions were carried out with respect to other "Doing Business" indicators, in parti cular:  
- The "Getting electricity" indicator: liberalization of the sector and exemptions for solar 
power kits should reduce the time and cost involved in getting electricity;  
- The "Dealing with construction permits" indicator: adoption and enactment of the 
Urban Planning Code and its implementing regulations and definition of the permit 
application procedure (transferred to mayors' offices). Costs and time periods have been 
considerably reduced;  
- The "Trading across borders" indicator: professionalization of t he sector through the 
organization of approved agents, and enactment of a new Customs Code in which the 
container -based tax system was abandoned in favour of a value -based percentage 
system. The possibility of making an online customs declaration was also introduced.  
•Number of business start -up procedures reduced to eight  
•Time taken reduced to 15.5 days compared with African average of 
29.7 days  
•Introduction of the single window  
•Dissemination of OHADA Uniform Acts  
•Reduction of minimum capital from KMF 750,000 to KMF 100,000  
•Reduction of business start -up cost from KMF 86,000 to KMF 51,000 
for a limited liability company.  
Starting a business  
• Reduction of registration cost fr om 15% to 9%  
• All information on registration regulations and procedures accessible 
through the e -regulations portal  
Registering property  
•Establishment of a central risk department for banks and financial 
institutions to minimize borrower payment risks  
•Adoption of a regulatory framework for financial leasing  
Getting credit   
•Establishment of a Court of Arbitration and Mediation (CACOM) by 
the Union of Chambers of Commerce and Industry of the Comoros 
(UCCI)  
•Training for judges and court officers on the OHADA Uniform Act  
•Establishment of the commercial court  
•Appointment of trial preparation judges to reduce referrals  
Enforcing contracts   WT/ACC/COM/34  
 
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  Question 4  
Could Comoros please give some concrete examples on what has already been done to 
combat corruption? Why was the previous anti -corruption body dissolved? When will a 
new anti -corruption body be established?  
Answer : 
Some specific examples are provided below of what has already been done to combat corruption:  
- All candidates appointed to a position of responsibility,  including the President of 
the Republic, must make an annual asset declaration;  
- Ratification of the United Na tions Convention against Corruption (UNCAC);  
- Enactment of the Government Procurement Code;  
- Establishment and entry into operation of the  Regulatory Authority for Government 
Procurement;  
- Setting up of a national committee to prevent and combat corruption, w hich enabled the 
development of a strategy, adopted in 2013, setting the following lines of action: (i)  tackling 
areas of corruption; (ii) reducing the vulnerability of state employees; (iii)  rehabilitating and 
enhancing stakeholders and organizations that  demonstrate integrity; (iv) reducing risks of 
corruption; and (v) promoting a culture of rejecting corruption;  
- Adoption of a public finance management reform strategy 2014 -16 and renewal in 2016 -20; 
- Signing of the memorandum of accession to GIABA, a regio nal body that combats money 
laundering and the financing of terrorism;  
- Corruption is an offence punishable under the Law against Money Laundering and the 
Financing of Terrorism;  
- The Financial Intelligence Unit has been established and is operational;  
- Organ ization of various training courses on the following topics: fraud and corruption in calls 
for tender; civic values and good governance; anti -corruption justice system; combating 
money laundering, etc.;  
- Adoption of Decree No.  22-006/PR of 18  January  2022 e nacting Law No.  21-015/AU of 
29 June 2021 establishing the structure and operation of a judicial body for economic and 
financial matters.  
The previous anti -corruption body was dissolved for reasons relating to competence and qualification 
requirements for judicial activities. However, the competencies of the anti -corruption body were 
transferred to the division of the Supreme Court acting as the court of auditors, a division specializing 
in judicial matters relating to public accounts.  
- State ownership and privatization  
Question 5  
Could Comoros please give an update about work on the liberalization of imports of 
ordinary rice?  
Answer : 
The Ministry of the Economy requested the World Bank to conduct an impact assessment on the 
subject. The Wo rld Bank's January  2022 report recommends:  WT/ACC/COM/34  
 
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  1. a gradual liberalization of the importation of rice, on account of its social sensitivity; and  
2. meeting the necessary conditions for successful progressive liberalization prior to full 
liberalization.  
These include: (i) building the capacity of stakeholders and institutions involved in the importation, 
production and distribution of rice; (ii) encouraging regional integration to ensure a bigger rice 
market for local producers in order to promote their emergence; (iii) strengthening social protection; 
and (iv) reforming ONICOR.  
According to the World Bank report, ONICOR could primarily play a role as follows:  
1. In its strategic reorientation as a domestic enterprise: especially by pl aying a key role in the 
process of liberalization of the rice market as part of two solutions recommended by the 
World Bank report.  
 
It would be a key player in the implementation of a plan of liberalization based on 
communication, involvement and awarenes s-raising with regard to all players in order to 
attract broad support for reform and achieve wide -ranging consensus with regard to 
successful liberalization of the sector;  
2. In regulating the rice market: by promoting competition and the removal of restrict ive rules 
or social obligations on importers;  
3. In guaranteeing domestic supplies: to ensure the ongoing supply of high -quality rice at 
affordable prices.  
Two solutions may be considered regarding the strategic reorientation of ONICOR over the short and 
medium term:  
1. Role as a central procurement agency (during a transition period); and  
2. Management of strategic rice stocks.  
ONICOR could help the country maintain sufficient rice stocks on the market – particularly in 
response to economic shocks.  
- Pricing po licies  
Question 6  
In connection to necessities during the COVID -19 crisis, it is noted that guarantee funds 
for importers have been set up. Could Comoros please explain about price control 
measures that would aim to ensure lower prices for the final consum er? 
Answer : 
The country experienced three successive shocks from the outside, with an impact on prices and 
sufficient availability of products. The Government supported economic operators in order to 
facilitate the importation of staple products. During the month of Ramadan, price support for staple 
products was put in place after negotiation with private sector representative bodies. An order of 
the Minister responsible for trade establishes price controls during the month of Ramadan. Controls 
are based on this commitment to price moderation.  WT/ACC/COM/34  
 
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  IV. POLICIES AFFECTING TRADE IN GOODS  
C. INTERNAL POLICIES AFFECTING FOREIGN TRADE IN GOODS  
- Sanitary and phytosanitary standards  
Question 7  
(a) Could Comoros please give an indication of which products that will not be subject to 
sanitary and phytosanitary certification? (b) Would Comoros have a list of which food 
products that would need a sanitary and phytosanitary certification issued by officials of 
the country of origin?  
Answer : 
a) Products that will not be subject to sanitary and phytosanitary certification are those that 
generally do not pose a sanitary or phytosanitary risk or hazard likely to be detrimental to 
human, animal, plant or environmental health or to food safety.  
b) Yes. Comoros is  planning a list of food products that would require sanitary and 
phytosanitary certification from home country officials.  
At all events, Comoros does not prohibit the entry into its territory of a foodstuff; such a measure 
might constitute a market access  restriction, discrimination or a disguised restriction on 
international  trade.  
VII. TRANSPARENCY  
Question 8  
Could Comoros please indicate if it has already or is planning to take part in training 
activities on notification organized by the WTO?  
Answer : 
The Union of Comoros has participated in various training activities on notifications organized by 
the WTO. Training activities on notifications are included in the technical assistance plan.  
VIII.  TRADE AGREEMENTS  
Question 9  
Could Comoros please give a state of play of the ratification process of the 
African  Continental Free Trade Agreement? Where is the ratification procedure taking 
place?  
Answer : 
Comoros has signed the African Continental Free Trade Agreement and is in the process of submitting 
it to the National Assembly for ratification. A process to publicize the African Continental Free Trade 
Area is being initiated by the Ministry of the Economy with support from the UNDP.  
- OTHER  
Question 10  
Could Comoros please indicate if it has considered joining the WTO Joint Initiative 
negotiations on services domestic regulation, e -commerce and investme nt facilitation? WT/ACC/COM/34  
 
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  As well as the work on trade and women's economic empowerment and the work on trade 
and micro, small and medium -sized enterprises (MSMEs)?  
Answer : 
The Union of the Comoros is interested in the WTO Joint Initiatives on services domestic regulation, 
e-commerce and investment facilitation, as well as the work on trade and women's economic 
empowerment and the work on micro, small and medium -sized enterprises (MSMEs).  
Within the limits of its capacity to participate in these negotiations, the Union of the Comoros might 
consider associating itself fully or partially with the subjects of the negotiations.  
 
 
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